• IRS Hearing on U.S. Foreign Account Tax Compliance Act (“FATCA”) Reveals Major Themes   
  (May 16, 2012)
  The IRS hearing yesterday on the proposed FATCA regulations included 20 speakers over three-and-a-half hours. IRS and Treasury Department representatives asked no questions, so those hoping the government would tip its hand regarding the direction of the final regulations and foreign financial institution (“FFI”) Agreement went away disappointed ...   
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• Final Regulations on U.S. Bank Deposit Interest (“USBDI”) Reporting Strengthens U.S. Foreign Account Tax Compliance Act (“FATCA”) Position   
  (May 7, 2012)
  The U.S. is hoping to turn FATCA into a multilateral tax reporting regime, and has already announced that five partner agreements are being negotiated; an additional country, Ireland, has also stated that it is negotiating with the U.S., and upwards of 40 other countries are rumored to be in talks ...   
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• Cost Basis on Bonds and Options Delayed One Year   
  (May 3, 2012)
  Occasionally, even the IRS shows some mercy. Brokers have been phasing in cost basis reporting for stocks over the last year-and-a-half ...   
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• Synopsis and Comments on the Proposed FATCA Regulations   
  (February 13, 2012)
  The U.S. Treasury and IRS published the proposed Chapter 4 FATCA regulations (“Regulations”) and the preamble (“Preamble”) to them on February 8, 2012 -- a daunting 388 pages of detailed rules ...   
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• "FATCA Partnerships" – Are They the Cure for FATCA?   
  (February 10, 2012)
  The United States announced on February 8, 2012, that it is pursuing “FATCA Partnerships” with France, Germany, Italy, Spain and the United Kingdom. The purpose of the agreements is to help “foreign financial institutions” (“FFIs”) in these jurisdictions (“Partner FFIs”) to avoid local “legal impediments to compliance ...   
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• Dividend Equivalent Payments Subject to U.S. Withholding   
  (January 24, 2012)
  The U.S. Treasury and IRS have taken the next step in their crackdown on transactions that avoid the U.S. withholding tax on U.S. source dividends. Recently issued temporary and proposed regulations define when a payment that references a U.S. source dividend ...   
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• FATCA Transition Relief: Notice 2011-53   
  (July 15, 2011)
  The IRS has responded to industry and foreign government concerns regarding the January 1, 2013, effective date of the chapter 4 provisions of FATCA...   
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• Immediate Action Required for Participating FFIs with Respect to Responsible Officer Certifications
  (May 6, 2011)
  Although FATCA is not effective until January 1, 2013, foreign financial institutions (FFIs) that intend to enter into FFI Agreements with the IRS (“participating FFIs”)...   
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• IRS Releases Notice 2011-34 – Second FATCA Notice    
  (April 11, 2011)
  On April 8, 2011, Treasury and the IRS issued a second FATCA notice, Notice 2011-34 (the "Notice") supplementing Notice 2010-60 and providing new guidance in several...   
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• IRS Comments on FATCA Notice 2010-60   
  (September 23, 2010)
  Several senior IRS executives addressed the Tax Executives Institute in New York City on September 22, 2010, as part of a panel chaired by John Staples, and commented on FATCA Notice 2010-60 (the “Notice”)...   
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• First Round of FATCA Guidance Published by IRS    
  (August 30, 2010)
  On Friday, August 27, the IRS published Notice 2010-60 (“Notice”), the first round of guidance under the Foreign Account Tax Compliance Act (“FATCA”) provisions ...   
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• Notice 2010-46: New Securities Lending/Repo Rules: Notice 2010-46 Replaces Notice 97-66   
  (May 24, 2010)
  What is the purpose of Notice 2010-46? The Notice implements section 871(l)(6) of the Foreign Account Tax Compliance (“FATCA”) provisions of the HIRE ...  
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• U.S. Withholding and Information Reporting on Dividend Equivalents Begins September 14, 2010  
  (April 16, 2010)
  ALERT: Clients should be aware that new section 871(l) enacted as part of FATCA requires withholding on dividend equivalents beginning on or after September 14, 2010. Prompt action is required. This alert describes dividend equivalents and ...  
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• FATCA is Now Law  
  (March 18, 2010)
  Today, the President signed into law a major revamp of the U.S. withholding tax system that imposes a new 30% withholding tax on certain U.S. source payments made to foreign financial institutions (“FFIs”) and non-financial foreign entities (“NFFEs”) that refuse to identify certain U.S. persons invested with them offshore, even if ... 
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• Do You Have a 2010 Strategy to Deal with Cost Basis Reporting and FATCA?  
  (February 8, 2010)
  Proposed regulations mandating cost basis reporting (“CBR”) and potential passage of the Foreign Account Tax Compliance Act (“FATCA”) constitute the biggest operational and systemic challenges that U.S. and non-U.S. financial institutions have had to face since... 
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• Likely Consequences to Financial Institutions from the IRS Voluntary Disclosure Program for U.S. Holders of Undisclosed Offshore Accounts  
  (January 28, 2010)
  Over 14,000 U.S. taxpayers trying to escape criminal prosecution have voluntarily disclosed their offshore accounts to the IRS in the last few months. More such... 
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• U.S. Withholding Tax Legislation Introduced on October 27, 2009
  (October 30, 2009)
  Key Congressional tax writers introduced the “Foreign Account Tax Compliance Act of 2009” (“Act”) on October 27, 2009, with the U.S. Treasury expressing its support...
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• Drastic Changes to Qualified Intermediary (“QI”) Program Proposed by Obama
  (May 7, 2009)
  The Obama Administration has proposed to Congress sweeping changes in the QI program and the way nonqualified intermediaries (“NQIs”) are treated.  If these proposals are adopted,...
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